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3.0 Treatment Items - Facility Wide : 20 <br /> 3.2 SWPC have now issued a Logbook : Batch Production Plant : Filter Press <br /> Operation, and is located in the Pickling Operators office. This will accurately reflect when <br /> the Filter Press is used, what it is being used for, and how much waste is generated. A <br /> copy of the logbook contents is attached. <br /> See Appx 2 <br /> 4.0 Treatment Items - Facility Wide : 32 <br /> 4.1 22 CCR 66265.33 Eyewash in the Waste Management area has been properly <br /> repaired, and photo is attached. See photo # 3 <br /> 5.0 Notice to Comply : <br /> 5.1 Item 33 : Secondary containment. When the facility was built in 1979, secondary <br /> containment was not a requirement, but was installed to both the tank area and waste <br /> management area. 2 separate reports have been made to confirm the integrity of the <br /> secondary containment system, 1 by Alexander Scheflo and Associates in March 1993, <br /> and 1 by Wallace Kuhl and Associates in August 1994; both of these reports confirm that <br /> our secondary containment is adequate. Copies of both of these reports is attached. <br /> See Appx 3 and 4. <br /> 5.2 Item 34 : WIG solids hazardous waste determinations. <br /> WIG solids were sent to Twining Laboratories Inc, an independent testing lab, for STLC <br /> and TTLC profiles. Results are given in Appx 5, and as they are below the thresholds of <br /> 22CCR: 66261.24 and Title 26:22-66261.24, SWPC are claiming that this is a non- <br /> hazardous waste, and does not require to be disposed of in Kettleman Hills, but can be <br /> disposed of in a local land-fill. <br /> 6.0 Additional Specific Violations : DTSC letter dated August 1st, 1995 <br /> 6.1 Section 25143.99(a) Health and Safety Code <br /> Section 66262.34(f) Title 22, California Code of Regulations <br /> All ferrous sulfate bags have been now been clearly marked with the following <br /> 6.1.1 the date upon which each period of accumulation began <br /> 6.1.2 the composition and physical state of the material <br /> 6.1.3 the statement that calls attention to the particular hazardous properties of the <br /> material <br /> 6.1.4 the name and address of SWPC as the material generator <br /> 6.1.5 container clearly marked stenciled with the words"Excluded Recyclable Material' <br /> All ferrous sulfate bags that were onsite ready for shipment were marked prior to <br /> shipment, and all future bags will be similarly marked [see attached photo #4]. <br /> 6.2 Section 25143.10 Health and Safety Code (a) <br /> Since the DTSC/Alternative Technology Divn on 11/22/91 had advised us that the ferrous <br /> sulfate was not a waste, and that HSC Sect 25143.2 would not be applicable, we did not <br />